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July 18, 2011

Petition to Delist Coho Salmon presented by Siskiyou County Water Users Association

347 N. Main St.

Yreka, Ca. 96097

530 842-4400

Prepared By

Dr. Richard A. Gierak

Bachelors Degrees in Biology & Chemistry, Doctorate in the Healing Arts, Director of Interactive Citizens United, Director of New Frontiers Institute, Inc. Prior Participant of FERC and FPAT (Fish passage advisory team) and HET (Hatchery evaluation team) Prior Vice President of Greenhorn Action Grange, Prior California State Grange Spokesman for the Water Committee, Prior National Whip of the Property Rights Congress of America, Representative of the Grange States of California, Oregon, Washington and Idaho regarding EFH regulations, Science consultant to Siskiyou County Water Users Association.

Statement identifying the taxon

Coho Salmon, Silver Salmon, Oncorhynchus kisutch...a salmonid which is a vertebrate fish

Reasons for nominating the taxon for delisting

This petition refers to the listing of Coho Salmon in the Klamath Basin including the Klamath River, Trinity River and associated waterways that empty into the Klamath River.

Known distribution of the taxon.

Occupies the entire Pacific Coastal region is herein challenged. This petition specifically refers to Northern California and the present listing of Coho Salmon as endangered under the California Endangered Species Act on the Klamath River and the proposed Federal ESA listing of Coho Salmon..

Known threats which may affect the taxa.

Nature--Estuarine destruction--predation--over fishing--by catch--Ocean temperature--Climatic changes

Endangered Species Act of 1973

There is no provision for listing a species that is not indigenous to the ESU. To this date there is no historical evidence indicating that Coho Salmon were ever indigenous to the Klamath Basin.

In 2001, Not one person on the Karuk Tribal Council believed that Coho salmon were native to the Klamath River,

Within the Tribe’s jurisdiction between Bluff Creek and Clear Creek on the California portion of the Klamath River, which is approximately between 91 and 140 miles below the lowest slated dam, Iron Gate, for removal this statement is reflected for example, in the minutes of the Karuk Tribal Council Meeting of December 27, 2001: Discussion was held by the Tribal Council and whether or not they [Coho] were ever present in the main streams and tributaries… …“Council states it may be easier to prove the Coho were never present“, and also the comment was made that if they were never here, then “they should not be encouraged to come back.”. The tribe named the river the Klamath, which translated means “Stinky River” and would not support salmon.


Karuk tribal history dates back to 1700 when there were an estimated 2,700 members present and there is no mention of Coho or Silver Salmon prior to plantings in 1895 and 1899.


1913 California Fish and Game Commission Report

(CFGC 1913) , W. H. Shebley, Superintendent of Hatcheries, writes “Strange as it may appear, the presence of the silver [Coho] salmon in the waters of this State remained unnoticed until Dr. Gilbert, Prof. of Zoology at Stanford University, a few seasons ago called attention to them. Heretofore, all the salmon taken in our rivers have been commercially classed as Quinnat [chinook]”. Any reported Coho were as a result of plantings in the Klamath River in 1895 and 1899. “Most of the salmon and steelhead eggs were taken at the [Redwood Creek] substation, as there was no run of either kind of Salmon in the Trinity River“.


Records from History as stated by CA Department of Fish &Game

Quotes; “The earliest record of Coho salmon being stocked in the Klamath Basin was of a plant made in 1895. Further examination of the original records from the U.S. Commission on Fish and Fisheries (1895) revealed those fish were raised in the Ft. Gaston facility in Hoopa and were stocked in the Trinity River and in Supply Creek, a tributary to the Trinity River. Those fish were reared from eggs taken at a facility in Redwood Creek… and also from eggs shipped from another facility not identified in the report (but were likely from out of the basin).”


Coho Salmon were not native

Dr. Ken Gobalet Professor of Biology Ph.D. California State University, Bakersfield

“The rarity of salmonids in archaeological materials suggests that the ethnographic record overstated the importance of salmonids to the Native Americans of California

No salmon remains of any kind were found south of San Francisco

. Chinook salmon were the most abundant salmonid in the Sacramento River drainage. No salmonids were found in the archaeological record in the San Joaquin River drainage south of San Joaquin County.”


Dr. Gobalet performed the research on the San Lorenzo River in Santa Cruz and his archeaological evidence (ie excavation of middens at village sites) that proved that Coho were not native to the Lorenzo river. It has been ignored by the agencies....but it has not been used as evidence in a court case....yet The study only applies south of Pescadero Creek. He was hired to do more work down here and found no Coho Salmon remains.


Historical Coho sightings in California

“Coho were recorded in 1936 and 1981 from streams in northern San Francisco Bay (Marin County) (Brown and Moyle 1991)”.(Peter Moyle is a warm water inland fish person, not an anadromous trained or studied person) This was most likely as a result of multiple plantings in California Rivers by Fish and Game with the earliest plantings in 1895 and 1899 followed by massive plantings in the 1960‘s and 1980‘s. “Historically, Coho were reported from streams as far south as the Santa Ynez River (Santa Barbara County) (Bryant 1994)”, Once again these are most likely as a result of the massive plantings in the 1960’s and 1980’s in Northern California. “With respect to the San Francisco Bay, no Coho populations are known to spawn in streams emptying into the bay. Although there are no historical records indicating spawning populations on the bayside of San Mateo County, Coho were recorded in 1936 and 1981 from streams in northern San Francisco Bay (Marin County) (Brown and Moyle 1991)”. Plantings of Coho in Northern California rivers in 1895, 1899 and the 1960’s and 1980’s are indicative of the source of these recorded sightings considering their genetic signature is that of Coho Salmon from Cascadia, Oregon.


FINAL Report_Coho Salmon-Steelhead_Klamath Expert Panels_04 25 11


Genetic Analysis of Hatchery vs. Natural Salmon

The initial statement regarding the controversy between "natural" and "hatchery" fish was made in a report by Busack and Currens in 1995, wherein they stated, "Interbreeding with hatchery fish might reduce fitness and productivity of a natural population", and picked up by noted Ecologist Dr. Richard Primack and many Environmental Radicals and utilized in a listing petition for Cutthroat Trout in the Colorado River. Mr. Michael Rode of the California Department of Fish and Game at a Hatchery Evaluation meeting on September 19, 2002 at Iron Gate Hatchery disclosed that less than a 2% genetic survey has been taken to date and no genetic differences have been noted between "hatchery" or "natural" Coho Salmon. A 2011 report by the Expert Panel indicated that their genetic analysis indicated the Salmon in Northern California were from Cascadia, Oregon plantings.

California Fish & Game

Finfish and Shellfish Identification Book” published in December 2006 does NOT list Coho Salmon as being present in California waters.

Expert Science Panel


“Weitkamp et al. (1995) suggested that natural origin Coho production in the SONCC ESU may not be currently sustainable. Further reduction in survival at sea in response to climate shifts has the potential to offset potential improvements in the freshwater environment, or it could cause further reductions or even extinction of natural origin Coho populations that are presently threatened with extinction.”

It is also to be noted that upon genetic analysis of the Coho Salmon in the Klamath Basin appears to be from plantings from Cascadia, Oregon. This statement also verifies the statement that Coho Salmon were never indigenous to the Klamath Basin. “The final expert report on Coho and steelhead appears to indicate that the extinction of the Coho Salmon looks like it cannot be avoided. It does not appear that it is resource users (timber, farming, mining,) in the mid-Klamath is the reason, but is instead Ocean and climatic conditions.”

FINAL Report_Coho Salmon-Steelhead_Klamath Expert Panels_04 25 11

Quote from 2009 Water Quality Klamath TMDL scoping comment responses

"The Regional Water Board can not establish life cycle-based water quality objectives for the mainstem Klamath River because the DO concentrations associated with salmonid life cycle requirements can not be met even under natural conditions- conditions in which there are no anthropogenic influences. As such, the Regional Water Board staff has proposed water quality objectives that protect natural DO conditions from further degradation."

1800’s Explorers comments

Explorers noted when first visiting the Upper Klamath Basin that water quality was so undesirable that even their riding horses and pack animals would not drink let alone support salmon populations.


Based on evidence presented in this petition Coho Salmon were never indigenous to the Klamath River and the listing of Coho Salmon by California ESA and Federal ESA should be considered unlawful, arbitrary and capricious. Concluding that Coho Salmon were not indigenous there is no provision in the Endangered Species Act to list a non-native species.

Respectfully Submitted;

Leo Bergeron

SCWUA President




June 23, 2011

Siskiyou County Water Users Association has submitted a second Coho delisting petition to delist Coho Salmon in the Klamath Basin based on the following parameters.

1. There is no historical evidence that Coho Salmon were ever indigenous to the Klamath Basin.





FINAL Report_Coho Salmon-Steelhead_Klamath Expert Panels_04 25 11

2. The Karuk tribal Council meeting of Dec. 27, 2001 indicated that Coho Salmon were never in the Klamath River and they should not try to bring them back.


3. In a 1913 California Fish & Game Commission report indicated there were no run of either kind of Salmon in the Trinity River even after Coho were planted in 1895 and 1899.

4. There is no provision in the Federal Endangered Species Act for listing a non- indigenous species.


5. California ESA and NMFS are in violation of the Endangered Species Act by listing Coho Salmon which is unlawful, arbitrary and capricious.

6. U.S. Fish & Wildlife service are in violation of their mandates which are restricted to freshwater species only. By being involved in the KBRA and KHSA regarding a saltwater species, ie: Salmon, their actions are unlawful, arbitrary and capricious.


7. Based on these historical records and the violation of the Federal Endangered Species Act Coho Salmon must be removed from the endangered list in California.

Respectfully submitted;

Leo Bergeron

SCWUA president

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